In the modern marketplace, private third party electronic data is the raw material for a substantial, and growing, percentage of both commercial and non-commercial processes. Private data, such as a consumer's identity information, financial information, health care information and law enforcement records, is extremely valuable. Such data enables efficient automation of commercial and non-commercial processes while increasing process integrity through the integration of complex business rules which act on such data. Like anything of value, such data is often misappropriated for criminal purposes or utilized for unintended or non-compliant uses. At the same time, the legitimate demand for such data creates a need for unencumbered, automated access. The competing preferences of securing such data and making such data readily obtainable to facilitate legitimate commercial and non-commercial activity must be balanced in order to preserve marketplace liquidity, prevent criminal activity and preserve privacy. The balancing of these competing preferences most often results in complex, nested governmental regulatory requirements. Complying with such regulatory requirements typically has a significant overhead cost and often inhibits the deployment of efficient processes.
For example, banks, credit issuers and collection agencies must have current information on consumers in order to profitably extend credit and collect on delinquent accounts. This data allows the issuers of credit to offer capital to individuals across the spectrum of risk. Relative to the collection of delinquent accounts, businesses use the traditional methods of skip tracing to gather information on consumers while attempting to comply with the constantly changing, complex regulations concerning the use of such information. In addition, the information obtained through these traditional methods is often incorrect or outdated because it typically originates through a third party data broker which aggregates such information from a limited number of sources.
Many industries, such as mortgage application processors, utility companies and retail establishments, collect vast amounts of current information on individuals and business entities. These companies could earn revenue by providing timely data records to legitimate companies for legitimate purposes. However, the transfer of such data, being controlled by strict governmental regulation, makes it expensive and difficult to provide such data to legitimate users. As a result, a large and growing number of such entities could participate in the marketplace as data providers, but choose not to because of burdensome regulatory requirements and a general lack of expertise in connecting to the marketplace and selling such data.
In addition, there exists in the market a significant barrier to the aggregation of such data from such entities. An entity which aggregates and resells such data may very well be categorized as a regulated entity under such regulatory schemes as the Fair Credit Reporting Act (FCRA). Thus, there are potentially significant barriers not only for the providers of such data, but for the brokers of such data. The regulations governing brokers of such data may often be more complex and difficult to comply with than the regulations governing the providers of such data. Therefore, data brokering entities typically must charge a premium for brokered data.
There exists a need for a system that permits a third party intermediary, in what might traditionally be viewed as the role of a data broker, to facilitate a non-burdensome, compliant and timely provisioning of information from non-traditional data providers to data buyers directly, while mitigating the additional regulatory overhead costs typically associated with the role of a data broker. By facilitating the direct, anonymous exchange or such information between system users without gaining specific knowledge of the data exchanged, the third party intermediary is transformed from being a data broker to being a facilitator of direct exchange. In addition, such a system necessarily requires a mechanism which protects the significant capital outlay of the facilitator of direct exchange in establishing a network by preventing the users of such a network from learning the identity of the other network members. In the market today, no systems known in the art facilitate the exchange of private data between business entities with anonymity.
There exists a further need for a system to facilitate the anonymous purchase and sale of timely private data which enables the users to meet applicable regulatory requirements and the facilitator of the system to minimize regulatory obligations incumbent on traditional data brokers.